MiCA Rules Sufficient for Stablecoins, EBA Confirms in Latest Update

November 19, 2025

EU Maintains Regulatory Course Despite Central Bank Concerns

The European Banking Authority affirmed this week that existing Markets in Crypto-Assets regulations provide sufficient tools to manage stablecoin risks, dismissing calls for urgent amendments despite recent warnings from the European Central Bank and European Systemic Risk Board. The statement marks a significant regulatory divergence as European authorities debate how aggressively to regulate digital currencies that have grown to represent billions in daily transaction volume.

An EBA spokesperson acknowledged concerns raised by the ESRB regarding “potential massive redemption requests” but emphasized that these risks depend heavily on how individual stablecoin issuers manage their operations and business scale. Luis del Olmo, senior expert at the EBA, told Reuters that stablecoin issuers must manage liquidity to meet potential redemption requests effectively. Businesses managing treasury operations increasingly face these evolving compliance frameworks when they accept crypto payments for business activities across borders.

MiCA Framework Implementation Progresses

MiCA began taking effect throughout 2024, with stablecoin provisions activating on June 30, 2024, and comprehensive rules for Crypto Asset Service Providers coming into force on December 30, 2024. The regulation will reach full implementation by 2026 as the remaining technical standards are finalized.

Under the framework, stablecoin issuers must maintain adequate reserves held in highly liquid assets such as cash or government bonds covering entire circulation supply. Quarterly external audits verify reserve sufficiency and liquidity, while real-time disclosure requirements ensure transparency. The regulation prohibits stablecoins from offering interest to prevent them from functioning as unregulated savings instruments.

Transaction volume thresholds trigger enhanced scrutiny. If a stablecoin’s daily transaction volume exceeds €200 million (approximately $216 million), regulators may classify it as systemically important, subjecting the issuer to additional oversight. According to Reuters reporting on EU crypto regulations, Circle’s euro-regulated USDC stablecoin maintains around $75 billion in circulation, making it the largest EU-regulated token currently operating under these standards.

Regulatory Tensions and Competing Priorities

The EBA’s position contrasts sharply with recent warnings from other European financial authorities. The ECB and ESRB have expressed concerns that stablecoins could pose threats to financial stability, particularly during periods of market stress when redemption requests might spike dramatically. These institutions have called for banning “multiple issuance” models where various entities issue tokens backed by shared reserve pools.

Diagram mapping points of alignment and disagreement between EBA, ECB, and ESRB.

The disagreement reflects broader debates about balancing innovation with prudential oversight. The EBA appears more confident that existing rules provide adequate safeguards, while central banking authorities prioritize financial stability over market development. This tension will likely shape future regulatory refinements as policymakers observe how stablecoins perform during the next market cycle.

The regulatory divergence also highlights interpretive challenges within MiCA itself. The EBA awaits clarification from the European Commission regarding whether multi-issuance structures comply with current regulations. This uncertainty affects how issuers structure their operations and reserve management systems. Those exploring platforms that enable crypto onramp services must navigate these evolving interpretations carefully.

Compliance Timeline and Market Impact

The European Securities and Markets Authority issued guidance in January 2025 clarifying expectations for Crypto Asset Service Providers regarding non-compliant stablecoins. ESMA urged CASPs to prioritize restricting services supporting purchases of non-MiCA-compliant asset-referenced tokens and e-money tokens, with restrictions expected to be completed by the end of January 2025.

However, ESMA allowed CASPs to maintain services on a “sell only” basis through March 31, 2025, enabling EU participants to liquidate or convert positions in non-compliant stablecoins. According to CoinDesk analysis of MiCA implementation, this transition period aims to prevent disorderly market disruptions while moving toward full compliance.

Major exchanges have already begun delisting non-compliant tokens. Coinbase removed Tether’s USDT from European markets in mid-December, citing uncertainty about whether the world’s largest stablecoin issuer would seek MiCA authorization. Tether has shown apparent reluctance to apply for EU authorization, potentially excluding the dominant stablecoin from European markets unless the company changes course.

National Competent Authorities across the EU’s 27 member states bear responsibility for enforcing compliance with new rules. ESMA warned that delays resulting in “sudden actions to align with MiCA” could lead to “disorderly crypto-assets markets,” placing pressure on national regulators to act decisively while minimizing market disruption.

The enforcement phase marks a critical test for MiCA’s viability. How effectively national authorities implement standards and how market participants respond will determine whether the framework achieves its goals of protecting consumers while enabling innovation. Participants managing positions across multiple jurisdictions may find that tools offering efficient swap crypto capabilities between compliant and non-compliant tokens provide tactical flexibility during transition periods.

Interplay with the Payment Services Directive

An additional complication emerged from overlapping requirements between MiCA and the Payment Services Directive 2. The European Commission sent a letter to the EBA and ESMA on December 6, 2024, highlighting administrative burdens if dual authorization under both frameworks were required for e-money token services.

The letter noted diverging interpretations among member states regarding how MiCA and PSD2 interact, potentially creating inconsistent application of requirements across the EU. While PSD3 and the Payment Services Regulation, currently under development, may resolve these issues, the expected application date remains several years away.

The Commission proposed the possibility of a “no action letter” regarding enforcement of PSD2 authorization requirements for crypto-asset services involving e-money tokens that might inadvertently fall within PSD2’s scope. The EBA published a response on December 10, 2024, acknowledging concerns while emphasizing that payment services require tight regulation to maintain confidence in transaction stability and reliability.

The EBA’s June 2025 opinion on the interplay between PSD2 and MiCA concluded that crypto-asset services as defined under MiCA should not be deemed payment services subject to PSD2 licensing. The authority advised national regulators not to regard intermediation of crypto-asset purchases with e-money tokens as payment services requiring separate PSD2 authorization, significantly alleviating dual-authorization burdens during the transitional period.

Global Implications and Forward Look

MiCA represents the world’s first comprehensive regulatory structure for digital assets, establishing a potential template for other jurisdictions developing their own frameworks. The EBA’s assessment that existing rules suffice suggests European regulators believe they have struck an appropriate balance between oversight and innovation.

However, the regulatory approach carries competitive implications. Stringent requirements may drive some stablecoin issuers to operate from jurisdictions with lighter oversight, fragmenting global liquidity and potentially undermining financial stability goals. Conversely, clear regulatory standards could attract institutional capital seeking compliance certainty unavailable in less-regulated markets.

The transatlantic regulatory divergence particularly matters. The United States has pursued enforcement actions against crypto firms while developing affirmative frameworks more gradually. If European standards prove workable and attract market share, American regulators may face pressure to provide comparable clarity.

Whether this framework withstands market stress remains unknown. The next significant downturn will test whether reserve requirements and redemption mechanisms function as designed during panic selling. The disagreement between the EBA and ECB suggests ongoing regulatory evolution rather than settled conclusions. Those tracking developments through comprehensive crypto market prices can monitor how regulatory clarity affects token valuations and trading volumes across different jurisdictions.

For market participants, the message remains clear: European authorities have established comprehensive rules and expect compliance. The transitional period for adaptation is concluding, and enforcement will intensify throughout 2025. Organizations operating in EU markets must prioritize MiCA compliance or risk losing access to one of the world’s largest economic regions.

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Faran Maood

Faran Maood

Faran specializes in covering technical developments, market analysis, and emerging trends in digital assets.